The Transparency in Coverage (TiC) rule: Posting Machine-Readable Files

The Transparency in Coverage (TiC) rule: Posting Machine-Readable Files

What is it?

In November 2020 the federal government issued final regulations to implement an ACA requirement regarding health care pricing transparency applicable to group health plans and health insurers. Pursuant to these rules, group health plans and health insurers are required to disclose specified cost-related data to the public in machine-readable files (MRFs).

There are 2 types of client-specific files that are available:

  • In-Network Rate File – all rates paid to in-network providers for covered services.
  • Out of Network Rate File – billed charges and allowed amounts for covered services.


Nippon Life Benefit’s Action Plan:

Nippon Life Benefits has published the required MRFs on its publicly available website. They can be viewed here. Machine readable files will not be published in PDF or Excel. They will be published as a JSON file. These files are created to allow researchers, regulators, and application developers to access and analyze data more easily. They are not intended for Employer and Employee viewing.

  • All Out-of-Network files have been posted and listed as Nippon Life, <client EIN>Allowed Amounts
  • In-Network files are being posted as they become available


Group health plans and plan sponsors should consult with their own legal counsel regarding compliance with this Transparency in Coverage final regulation, including but not limited to its own machine-readable file disclosure obligations (e.g. linking to the Nippon Life Benefits’ website and the machine-readable file(s) specific to their group health plan).

What are next steps?

Employers will be notified when their group’s files are ready and posted on the Nippon Life Benefits website. It will be found under the Employer Notification Center. The employer can determine, by consulting with their own legal counsel, how they will link to the Nippon Life Benefits posted files.

The law does not require a notification to members regarding the availability of these files.

You can view your group’s Machine Readable Files (MRF) here.